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SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

OMB No. 1810-0036

IMPACT AID PROGRAM

APPLICATION FOR SECTION 8002 ASSISTANCE

A. Justification 

1. Explain the circumstances that make the collection of information necessary. Identify any legal or 

administrative requirements that necessitate the collection. Attach a copy of the appropriate section of 

each statute and regulation mandating or authorizing the collection of information.

The U.S. Department of Education is requesting approval for the Application 

for Assistance under Section 8002 of Title VIII of the Elementary and 

Secondary Education Act. This application is for a grant program otherwise 

known as Impact Aid Payments for Federal Property. Local Educational 

Agencies (LEAs) that have lost taxable property due to Federal activities 

request financial assistance by completing an annual application. 

Regulations for Section 8002 of the Impact Aid Program are found at 34 CFR 

222, Subpart B; however, a change to the funding formula contained in Section 

563 of the National Defense Appropriation Act for FY 2013 supersedes many of 

these regulations. 

This collection is a direct result of a statutory change included in Section 

563 of the National Defense Appropriation Act of FY 2013 (P.L. 112-239, 

January 2, 2013). The revised statute sets the eligibility criteria and the 

formula for determining grant payments under Section 8002. The application 

collects annual data required to calculate payments using the new formula. 

The Department of Education (ED) recently received emergency approval for 

this application, and now we request approval for a three-year clearance 

under the same collection number.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new 

collection, indicate the actual use the agency has made of the information received from the current 

collection.

The statute and implementing regulations (34 CFR Part 222, Subpart B) require 

annual data from LEA applicants. ED uses this data to determine an LEA’s

eligibility for the program and the amount of the applicant’s grant award. 

The least burdensome method of collecting this required information is for 

each applicant to submit it as part of its annual Impact Aid application, 

previously approved under OMB 1810-0036. 
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3. Describe whether, and to what extent, the collection of information involves the use of automated, 

electronic, mechanical, or other technological collection techniques or forms of information technology, 

e.g. permitting electronic submission of responses, and the basis for the decision of adopting this means 

of collection. Also describe any consideration given to using technology to reduce burden.

Applicants prepare and submit Section 8002 applications through an eapplication on ED’s www.g5.gov website. The e-application offers recurring 

LEA applicants significant advantages in preparing the application because it 

pre-populates much of the LEA’s identifying information and Federal property 

data. The e-application automatically checks for completion of all necessary 

items and includes arithmetic checks for table subtotals and the application 

total. This software reduces the number of errors in applications submitted 

to ED.

 

4. Describe efforts to identify duplication. Show specifically why any similar information already available 

cannot be used or modified for use for the purposes described in Item 2 above.

The information requested under these collections is not duplicated in any 

other data collection, is unique to this program and the particular 

applicants, and is intended to serve specific purposes mandated by the 

statute. 

5. If the collection of information impacts small businesses or other small entities (Item 8b of IC Data Part 

2), describe any methods used to minimize burden.

Small businesses are not impacted by this data collection. Approximately 250 

small LEAs complete this application. Program regulations clarify and 

standardize the reported information to minimize the burden for all 

applicants. Additionally, LEAs will be able to complete the FY 2015

application online through a program that pre-populates data from the LEA’s 

previous application. This means that the applicant only needs to enter 

information if it has changed.

6. Describe the consequences to Federal program or policy activities if the collection is not conducted or 

is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

The statute requires applicants to apply for funds annually and authorizes 

the payment of funds based upon those annual applications. Without the 

annual information, the Department would not be able to disburse these funds 

efficiently and accurately. 

7. Explain any special circumstances that would cause an information collection to be conducted in a 

manner:

 requiring respondents to report information to the agency more often than quarterly;

 requiring respondents to prepare a written response to a collection of information in fewer than 30 

days after receipt of it;

 requiring respondents to submit more than an original and two copies of any document;
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 requiring respondents to retain records, other than health, medical, government contract, grant-inaid, or tax records for more than three years;

 in connection with a statistical survey, that is not designed to produce valid and reliable results 

than can be generalized to the universe of study;

 requiring the use of a statistical data classification that has not been reviewed and approved by 

OMB;

 that includes a pledge of confidentiality that is not supported by authority established in statute or 

regulation, that is not supported by disclosure and data security policies that are consistent with 

the pledge, or that unnecessarily impedes sharing of data with other agencies for compatible 

confidential use; or

 requiring respondents to submit proprietary trade secrets, or other confidential information unless 

the agency can demonstrate that it has instituted procedures to protect the information’s 

confidentiality to the extent permitted by law.

The regulations do not require the information collection to be conducted in 

a manner inconsistent with the requirements of 5 CFR 1320.5.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal 

Register of the agency’s notice, required by 5 CFR 1320.8(d), soliciting comments on the information 

collection prior to submission to OMB. Summarize public comments received in response to that 

notice and describe actions taken by the agency in response to these comments. Specifically 

address comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on the availability of 

data, frequency of collection, the clarity of instruction and record keeping, disclosure, or reporting 

format (if any), and on the data elements to be recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or those who 

must compile records should occur at least once every 3 years – even if the collection of information 

activity is the same as in prior periods. There may be circumstances that may preclude consultation 

in a specific situation. These circumstances should be explained.

The Impact Aid Program Director regularly consults formally and informally 

with applicant LEAs, as well as with the leaders of the National Association 

for Federally Impacted Schools (NAFIS), the National Council of Impacted 

Schools (NCIS), the National Indian Impacted Schools Association, and the 

Military Impacted Schools Association. These consultations have yielded 

insight into the difficulties that school officials may have in completing 

the applications. The Department attempts to mitigate these problems 

whenever possible. A 60-and 30-day Federal Register Notice was published in 

the Federal Register. 

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of 

contractors or grantees.

The information collection does not require gifts or payments to be made to 

respondents. 

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in 

statute, regulation, or agency policy.
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The information collection requires no assurance of confidentiality. 

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and 

attitudes, religious beliefs, and other matters that are commonly considered private. The justification 

should include the reasons why the agency considers the questions necessary, the specific uses to be 

made of the information, the explanation to be given to persons from whom the information is requested, 

and any steps to be taken to obtain their consent.

The information collection does not include any questions of sensitive 

nature.

12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of respondents, frequency of response, annual hour burden, and an 

explanation of how the burden was estimated. Unless directed to do so, agencies should not 

conduct special surveys to obtain information on which to base hour burden estimates. 

Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour 

burden on respondents is expected to vary widely because of differences in activity, size, or 

complexity, show the range of estimated hour burden, and explain the reasons for the 

variance. Generally, estimates should not include burden hours for customary and usual 

business practices.

 If this request for approval covers more than one form, provide separate hour burden 

estimates for each form and aggregate the hour burdens in item 16 of IC Data Part 1.

 Provide estimates of annualized cost to respondents of the hour burdens for collections of 

information, identifying and using appropriate wage rate categories. The cost of contracting 

out or paying outside parties for information collection activities should not be included here. 

Instead, this cost should be included in Item 14.

For information collected beginning with the FY 2015 application (application 

due winter 2014), we estimate that it will require 1.5 hours per LEA 

respondent. 250 responses at 1.5 hours per response equals 375 total burden 

hours. The cost per response, at an average of $30 per hour for LEA staff, 

is $45 ($30/hour x 1.5 hours). The total estimated annual cost to the public 

of this collection is $11,250 ($30/hour x 375 total burden hours). 

13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from 

the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14.)

 The cost estimate should be split into two components: (a) a total capital and start-up cost 

component (annualized over its expected useful life); and (b) a total operation and maintenance 

and purchase of services component. The estimates should take into account costs associated 

with generating, maintaining, and disclosing or providing the information. Include descriptions of 

methods used to estimate major cost factors including system and technology acquisition, 

expected useful life of capital equipment, the discount rate(s), and the time period over which 

costs will be incurred. Capital and start-up costs include, among other items, preparations for 

collecting information such as purchasing computers and software; monitoring, sampling, drilling 

and testing equipment; and acquiring and maintaining record storage facilities.
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 If cost estimates are expected to vary widely, agencies should present ranges of cost burdens 

and explain the reasons for the variance. The cost of contracting out information collection 

services should be a part of this cost burden estimate. In developing cost burden estimates, 

agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB 

submission public comment process and use existing economic or regulatory impact analysis 

associated with the rulemaking containing the information collection, as appropriate.

 Generally, estimates should not include purchases of equipment or services, or portions thereof, 

made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not 

associated with the information collection, (3) for reasons other than to provide information or 

keep records for the government, or (4) as part of customary and usual business or private 

practices.

Total Annualized Capital/Startup Cost : 

Total Annual Costs (O&M) : 

____________________

Total Annualized Costs Requested : 

The only costs to respondents are those shown above for staff time for data 

collection and reporting. There should be no costs beyond those covered 

under customary and usual business practices.

14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the 

method used to estimate cost, which should include quantification of hours, operational expenses (such 

as equipment, overhead, printing, and support staff), and any other expense that would not have been 

incurred without this collection of information. Agencies also may aggregate cost estimates from Items 

12, 13, and 14 in a single table.

Federal costs associated with this collection of information are those 

normally associated with Department staff conducting program monitoring. 

Application Receipt and Logging

Applications Hours per 

Application

Total Staff 

Hours

Wage Rate for 

Personnel1

Total Receipt and Logging 

Cost

250 0.25 hours 62.5 $35.88 $2,243

Application Review

Applications Time in Review 

per Application

Total Staff 

Hours

Wage Rate for 

Personnel2

Total Cost of Review

250 18 hours 4,500 $46.64 $209,880

Total $212,123

15. Explain the reasons for any program changes or adjustments to #16f of the IC Data Part 1 Form.

The total burden hours is reduced due to the change in program statute that 

changed the formula used to calculate the appropriate funding for each LEA. 

 

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2013 Pay rate for a GS-12/1 = $35.88

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2013 Pay rate for a GS-12/10 = $46.64
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Total burden hours per year is reduced by 750 hours (3 hours per applicant) 

because applicants will no longer need to provide data for past years. When 

Congress revised the statute governing Section 8002 grants, it made the 

funding formula change retroactive to include payments from FY 2010 funds and 

forward. This necessitated gathering additional information for past years, 

increasing the burden estimate for the prior, approved emergency collection. 

Beginning with applications for FY 2015 funding (application due winter 

2014), applicants will not need to submit data from past years, reducing the 

estimated burden significantly.

16. For collections of information whose results will be published, outline plans for tabulation and 

publication. Address any complex analytical techniques that will be used. Provide the time schedule for 

the entire project, including beginning and ending dates of the collection of information, completion of 

report, publication dates, and other actions.

The collection of information does not require publication of the 

information or use of complex analytical techniques.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, 

explain the reasons that display would be inappropriate.

The OMB approval number will be displayed on the forms.

18. Explain each exception to the certification statement identified in the Certification of Paperwork 

Reduction Act.

There are no proposed exceptions to the certifications.